Free Motion to Disqualify Counsel - District Court of Connecticut - Connecticut

Case 3:00-cv-00835-CFD

Document 445

Filed 01/25/2005

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT

INDYMAC BANK, F.S.B. Plaintiff CIVIL ACTION NO. 3:00CV835 (CFD)

V.

MOSTAFA REYAD AND WAFA REYAD Defendants DATE: JANUARY 24, 2005

DEFENDANT S MOTION TO DISQUALIFY PLAINTIFF S ATTORNEY

Defendant Mostafa Reyad respectfully moves this Court to immediate disqualification of Plaintiff s IndyMac Bank, F.S.B. attorneys as well as their law firms. Plaintiff s attorney David R. Schaeffer on May 17, 2000, committed fraud upon this Court. Mr. Schaeffer on his own prepared eight (8) writs of garnishment against Defendant in the total amount of $ 12.8 million. He prepared the writs which started by: BY THE AUTHORITY OF THE UNITED STATES, And its memorandum. Mr. Schaeffer defrauded this Court and inspired or conspired with Honorable Garfinkel, U.S.M.J., who executed the orders. Mr. Schaeffer executed the writs, knowingly it is not authorized by this Court, see, the eight writs attached, and see the lower left corner of each page, indicating

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Case 3:00-cv-00835-CFD

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that it was prepared by Plaintiff s attorney s computer. These writs, inter alia, caused Defendant damages in the amount approximately fifteen million dollar ($ 15 million) Mr. Schaeffer in the lead attorney of this action before this Court as well as the exact action of this action filed in the District of New Jersey. His law firm is Brenner, Salzman and Wallman, and New Jersey action represented by Hughes Hubbard & Reed L.L.P., law firm, also under his supervision as he is the lead attorney. Mr. Schaeffer also hindered upon this Court and New Jersey Court, the filing of exact complaint in each Court until he obtained the attachment orders from each Court.

The magnitude of Defendant s damages obligates this Court to immediate disqualification of attorney Schaeffer and the above stated law firm.

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The Defendant Mostafa Reyad

By: Mostafa Reyad 2077 Center Ave # 22D Fort Lee, NJ 07024 Day Phone 203-325-4100

CERTIFICATE OF SERVICE

The undersigned certifies that on the captioned date has mailed the following; each of them a true and correct copy. 1. Connecticut United States Attorney Kevin J. O Conner, Esq. 157 Church Street, New Haven, CT 06510 2. Plaintiff s Attorney David R. Schaefer 271 Whitney Ave, New Haven, CT 06511 3. Wafa Reyad

Mostafa Reyad

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Case 3:00-cv-00835-CFD

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